On behalf of the Board of Directors of the Virginia Chapter of the Association of Public Safety Communications Officials (VA APCO), thank you to the CRC for the detailed and extensive work on this revision of the Minimum Training Performance Outcomes for Dispatchers. We are grateful for and appreciate the ongoing commitment and hard work of the CJSB, its various committees, and DCJS and its staff. 

Overall, we find the newly proposed minimum standard to be a general advancement of the training standards for Virginia's public safety telecommunicators (PSTs, or "dispatchers"). With these comments, however, we request reconsideration of the removal of basic training related to fire and emergency medical service (EMS) communications.

We appreciate that training standards promulgated by the Department of Criminal Justice Services, situated and authorized as it is in Virginia code, do not require training of non-law-enforcement functions. However, we assert here that optimal operation of any law enforcement function inherently requires basic understanding of the multi-functional components of that response, including fire and EMS. We further appreciate that this standard is only the minimum, and that academies are free and encouraged to train beyond it. However, we believe inclusion of basic fire and EMS communications are, indeed, minimum requirements for law enforcement telecommunications in the twenty first century, just as basic law enforcement concepts are critical to optimal fire and EMS communications operations.

To support our position, we refer reviewers to the following sections in the proposed standard:

**Criteria 1.2.2 - "typical components of communications centers"

Typical communications centers in Virginia include multi-discipline public safety communication, justifying basic education about fire and EMS functions, terminology, operations, and communications. We recommend APCO International's ANSI Standard (APCO ANS 3.103.2.2015) minimum training standards document as a well-rounded reference and source of material, available at https://www.apcointl.org/doc/911-resources/apco-standards/75-minimum-training-standards-for-public-safety-telecommunicators/file.html.

**Outcome 1.5 - "Identify call-taking and appropriate dispatching techniques"

The introduction of the term "multi-functional dexterity" in section 1.5 is laudable and apt. Taken in context with "typical" communications centers, additional basic training, namely fire and EMS basics, are required to achieve the outcome. Law-only telecommunicators will, by definition, be required to analyze requests for assistance via 9-1-1 for fire and medical needs. Calls which may be dispatched by a separate fire or EMS agency will require triage and/or handoff by the law enforcement telecommunicator. Time is of the essence and multi-functional familiarity will decrease delays between services, improving safety outcomes for the public.

**Criteria 1.5.4 - "Identify the appropriate techniques for dispatching law enforcement officers during time/life critical incidents"

The modern and correct effort to encourage and enable interoperable communications requires multi-functional  intercommunication between law enforcement and fire and EMS units on scene and, by definition, with telecommunicators. Notwithstanding the "dispatcher" terminology, the work of the telecommunicator involves significantly more than initial identification and dispatch of resources. As the proposed curriculum demonstrates, the telecommunicator's involvement is constant and critical. This will include interoperable communications with non-law entities, meaning basic understanding of such functions is essential. While "plain language" is a basis for working with unfamiliar units, it is not by itself a substitute for understanding the core functions of public safety or sufficient for consistent operation under stress and during critical incidents. Fundamental understanding of multi-function, multi-discipline public safety operation is central to optimal law enforcement performance.

**Outcome 1.9 - "Identify calls for service related to disaster(s) or potential disaster(s) and various rescue operations"

Outcome 1.9 includes Incident Command System (ICS) training, which is absolutely necessary and should be included. However, the context of the section is "disaster(s) or potential disaster(s) and various rescue operations." This incorrectly and narrowly associates ICS with only rescue and disaster operations. Relegating it conceptually to only "bad day" events unnecessarily reinforces the inconsistent application of ICS, which should be applied and utilized across incidents and events of all sizes and scopes. Please adjust language to make clear the universal application of ICS to public safety responses. Consistent with comments above on Criteria 1.5.4, we find full and efficient implementation of and operation within multi-function incident command systems benefits from basic familiarity with multi-disciplinary public safety operations. Given the limited time available in any course, we recommend considering requiring basic ICS coursework as prerequisite to the DCJS basic curriculum, specifically NIMS 700a and 800b, as well as ICS 100 and 200. These courses are required for most Virginia telecommunicators and are available online. Class time during DCJS basic dispatcher courses can be utilized to integrate NIMS and ICS training with basic telecommunications, helping contextualize incident command structures and operations within the PSAP.

**Section 5.3 - "Operate radio equipment"

Section 5.3 helpfully includes on-the-job training related to interoperable communications, including but not limited to COMLINC, referring to current and future iterations of Virginia interoperability solutions. Such systems, consistent with the Commonwealth's goal to improve public safety communications outcomes, implicitly include basic communications with fire and EMS units and associated knowledge, skills, and abilities.

**Various, including Criteria 1.4.2.8 and OJT 5.113 - TDD and services or deaf and hard of hearing (unrelated to fire or EMS)

We recognize that text-to-911, while not fully deployed, will be required by July 1, 2020 in each Virginia PSAP. (See 2018 General Assembly Senate Bill 418, which becomes law July 1, 2018.) While TDD and TRS are still the official and required forms of emergency communication with the deaf and hard of hearing community, we recommend inclusion of basic text-to-911 concepts based on widespread adoption and the new 2020 statutory deadline for providing text services in the Commonwealth.

Please accept these comments and suggestions in the context of the Board's appreciation of the hard work to date and to come, as well as the open and frequent communication and collaboration with DCJS staff. It is through relationships and partnerships like these that we collectively work to advance public safety communications in the Commonwealth. Thank you again for your time, commitment, and consideration.